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1 Hines Rd., Suite 202 Ottawa, Ontario
K2K 3C7 |
Tel: (613) 254-7246 Fax: (613) 254-7250 www.datajungle.com |
September 21, 2005
Craig Wilson
Senior Assistant Chief Accountant
Securities & Exchange Commission
450 Fifth Street, N.W.
Room 4561
Washington, D.C.
U.S.A. 20549
RE:
DataJungle Software Inc.
Form 10-KSB for the year ended December 31, 2004
SEC File No. 001-05996
Dear Mr. Wilson,
With reference to the Securities & Exchange Commission (the “SEC”) letter dated July 19, 2005, the following will provide a response to the comment regarding the Form 10-KSB for DataJungle Software Inc. (the “Company”) for the year ended December 31, 2004.
Report of Independent Registered Public Accounting Firm, page 33
Comments from SEC:
We note your response to prior comment no. 1. Based on your specific facts and circumstances, we will not object to the use of a Canadian audit firm. However, if your assets and operations in the United States become significant in the future, we expect you to engage a U.S. registered public accounting firm, consistent with our position outlined in Section 5.K of “International Reporting and Disclosure Issues in the Division of Corporation Finance” on the Commission’s website.
Response from the Company:
We will evaluate our position vis-à-vis the position outlined in Section 5.K of “International Reporting and Disclosure Issues in the Division of Corporation Finance” on a regular basis and engage a U.S. registered public accounting firm when such conditions dictate so.
We trust that you will find our response satisfactory. However, if you have any questions, please do not hesitate to contact us.
Yours truly,
DataJungle Software Inc.
/s/ Edward Munden
/s/ Larry Bruce
Edward Munden
Larry Bruce
President & CEO
Vice President Finance, Secretary & Treasurer
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